DIGITAL CPA SERVICES
Costa Shepin, CPA
International Tax Review
Summary of review topics and planning priorities
- Illustrative client
- U.S. consulting business owner
- Proposed decision
- Relocate overseas while continuing the business
- Review timing
- Before the move and any entity changes
- Scope of this example
- U.S. planning framework and coordination topics
01 Situation and objectives
The hypothetical owner operates a U.S. LLC, serves U.S. clients, and plans to live overseas. The objective is to evaluate the existing arrangement and organize the questions to resolve before finalizing the move.
02 Matters requiring review
Business structure
Compare the current U.S. arrangement with the foreign-country treatment of the entity and owner. Obtain the relevant local analysis before reaching a structural recommendation.
Residency and timing
Document the proposed move date, continuing state ties, where work will be performed, and transactions being considered.
Accounts and investments
Assemble an inventory of foreign financial interests and identify items requiring U.S. classification or reporting analysis.
03 Action plan and responsibilities
Assemble the fact pattern.
Client supplies ownership documents, recent returns, financial information, and the proposed residency timeline.
Compare the relevant tax positions.
U.S. and foreign-country advisors address their respective jurisdictions and identify points requiring coordination.
Confirm decisions and follow-through.
Record the selected course of action and establish responsibility for any separately agreed implementation or filings.
04 Open questions
- What is the anticipated country and date of residence?
- How does that country treat the existing business?
- Which changes or transactions are being considered?
- What further analysis is required before a recommendation?